CRM Data Retention Policies for CMMC: What to Keep, What to Purge

Most GovCon CRMs operate as data accumulators. Emails from 2018, opportunity records from lost bids, contact data for people who changed agencies years ago—it all stays. Under CMMC, every record containing CUI in your CRM is a record you must protect. Reducing your CUI footprint through proper retention policies reduces your compliance burden.

This article builds on our CUI-Safe CRM guide and relates to CUI data flow analysis for understanding where CUI persists.

Why Retention Matters for CMMC

NIST 800-171 control 3.8.3 requires organizations to 'sanitize or destroy information system media containing CUI before disposal or release for reuse.' This applies to CRM data:

• CUI that no longer serves a business purpose should be disposed of
• Disposal must be documented and verifiable
• Retention periods should align with contract requirements and FAR clauses

CRM Data Categories and Retention Periods

Synced Emails

Retain: Duration of active contract + 3 years (per FAR 4.703 record retention requirements)

Purge: Emails from lost opportunities after 1 year post-decision. Pre-solicitation correspondence after 2 years if no contract resulted.

Opportunity Records

Retain: Won opportunities: contract duration + 3 years. Active pipeline: indefinitely during pursuit.

Purge: Lost opportunities: archive CUI fields after 1 year, full purge after 3 years. No-bid decisions: purge after 6 months.

Contact Records

Retain: Active contacts indefinitely. Government personnel records with clearance information require protection while retained.

Purge: Remove clearance-level data for contacts no longer in active relationships. Retain basic contact info for historical reference.

Attachments and Documents

Retain: Active contract documents for contract duration + 3 years. Past performance documentation for active use in proposals.

Purge: Superseded versions immediately. Draft documents after final submission. RFP documents for lost bids after debrief period.

Implementation Steps

1. Classify existing data. Identify which CRM records contain CUI and which don't.
2. Define retention schedules. Use the categories above as a starting point, adjusted for your contract obligations.
3. Automate where possible. Configure CRM archival and deletion rules. Manual processes create compliance drift.
4. Document disposal. Log what was purged, when, by whom, and the retention policy that triggered it.
5. Include in your SSP. Document your retention policy and disposal procedures. Use our SSP template as a starting point.

For the full CRM compliance picture, review the CMMC CRM compliance checklist.